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Opportunities to enhance engagement



The final topic we explored in our Consultation was about IIROC’s engagement with Dealers – what was working well and what could be improved. We heard a range of feedback, summarized below.

 

Differences in approach on when to engage on new ideas

There were differing views and comfort levels on when is the best time to engage with a regulator on new ideas the Dealer is considering.

In some discussions, it was clear that the Dealer felt there was a strong and positive relationship with IIROC, where the collaboration was clear and the engagement was constructive. Some shared that they regularly pick up the phone to bounce ideas around and to get informal feedback and guidance.

“We feel that we have an open door with IIROC to discuss new business models, even if we don’t end up walking through it”
– Consultation interviewee

 

But in a few discussions, we heard that there is fear around engaging with IIROC (and other regulators) too early in the innovation process and resistance to share much in the way of detail before everything is properly fleshed out and vetted by their respective legal teams.

“We (firms) feel that we need to have all of the questions answered, ducks in a row and “i’s” dotted before we reach out to a regulator.” – Consultation interviewee
– Consultation interviewee

 

There was also a perception shared by some that there is a lack of openness to new ideas, and insufficient knowledge on the part of regulators when it comes to changing investor needs, particularly regarding digital expectations. Both factors appeared to play a role in the timing and degree of comfort in engaging with regulators earlier in innovation discussions.

“How can we work collectively with regulators on what we are trying to solve, instead of trying to interpret where the goal posts are and trying to maneuver around them?”
– Consultation interviewee

 

Appetite for more timely,bilateral dialogue

One of our Consultation objectives was to be able to have our discussions with the firm’s senior leadership – the Heads of Business, Strategy, Transformation, Marketing, etc. – as well as the legal and compliance executives with whom we more regularly engage. Not everyone accepted our invitation, but most did, and we were able to have what many described as a different, constructive and surprisingly positive dialogue around the future of our industry.

We heard a strong appetite to continue these kinds of discussions, with broader business representation from the Dealers that IIROC regulates, to better manage the pace of change and make faster and better decisions.

“This was a very valuable conversation for us. Can we do this more often, say, quarterly?”
– Consultation interviewee